Political agreement on fundamental overhaul of the international tax system
On 8 October 2021, the Inclusive Framework (IF) announced a further agreement backed by 136 (out of 140) members of the Inclusive Framework on the two-pillar approach. In the last few days, a number of countries that initially opposed the reform are now also signing up for it (e.g. Hungary, Ireland and Estonia). With this,
OECD Inclusive Framework agrees on two-pillar Approach for International Tax Framework
On 1 July 2021, the Inclusive Framework (IF) announced an agreement backed by 130 (out of 139) members of the Inclusive Framework on the two-pillar approach. This approach redesigns the international tax framework. Here’s a summary of the main points of the agreement: Pillar one Pillar One is intended to re-allocate the taxing rights of
Country-by-country reporting goes public!
On 1 June 2021, representatives of the European Parliament and the Council under EU Portuguese Presidency negotiated a Draft Directive on public country-by-country reporting (‘Public CbCR’) for big multinational groups. They provisionally reached a compromise agreement. Once this political agreement is endorsed, it requires European or non-European multinational groups or standalone undertakings to publicly disclose
Draft MLI positions of different territories reflect a range of views on BEPS implementation
As a result of a new legal instrument, changes to the allocation of taxing rights and the introduction of new anti-avoidance rules mean that, once ratified, businesses and individuals may no longer qualify for double taxation relief on a range of cross-border transactions and activities. Taxable presences, compliance burdens, and tax liabilities could increase, and
UK’s ‘Diverted Profits Tax’ proposes a 25% tax rate for taxpayers but leaves open questions
Background On 10 December 2014 HM Revenue & Customs (HMRC) released the diverted profits tax (DPT) provisions within its draft Finance Bill 2015. Upon initial review, the new rules could affect many more companies than one might have anticipated. Scope The DPT is a new tax, with a 25% rate on profits that are considered
BEPS Project: Time to take a closer look at treasury and intercompany financing
OECD Base Erosion & Profit Shifting (BEPS) Project: Time to take a closer look at treasury and intercompany financing Just before the New Year’s break, the OECD issued new discussion drafts in the context of the so-called ‘Base Erosion & Profit Shifting’ project as mandated by the G20, better known as ‘BEPS’. They are particularly
OECD webcast of 15 December 2014: Impact on intercompany financing
Today, the OECD broadcasted a webcast on the progress of its BEPS Action Plan. The expectations of this webcast were very high as the OECD had previously announced it would publish relevant Discussion Drafts after the webcast, which potentially could have a serious impact on intercompany financing. While the OECD gave insights into some items, such as interest deduction
OECD publishes PE discussion draft (artificial avoidance)
The OECD has published its discussion draft on the Preventing of Artificial Avoidance of permanent establishment (PE) Status. This publication follows the BEPS (Base Erosion and Profit Shifting) timeline. A fundamental change to the existing PE rules, with a potentially wide impact on many structures currently in use by MNCs, are proposed in the OECD
